Source: Supreme Court  

Why in News? 

Recently, the bench of Justices Surya Kant and N. Kotiswar Singh upheld the conviction in a murder case based on circumstantial evidence, holding that proof of motive is not essential and that a complete, unbroken chain of proven circumstances excluding all reasonable doubt is sufficient for conviction. 

• The Supreme Court held this in the matter of Chetan v. The State of Karnataka (2025). 

What was the Background of Chetan v. the state of Karnataka (2025) Case? 

• The appellant and the deceased Vikram Sinde were friends who had a financial dispute over Rs. 4,000 that the appellant had borrowed from one Ravindra Chavan to lend to the deceased. 
• The deceased failed to return the borrowed amount of Rs. 4,000 to the appellant even after 7-8 months, despite repeated demands for repayment. 
• There was an argument between the appellant and the deceased regarding the money, during which the deceased allegedly insulted the appellant, creating a grudge between them. 
• On 10th July, 2006, at around 8:30 PM, the appellant took his grandfather's 12 Bore D.B.B.L gun with cartridges under the pretext of going hunting. 
• The appellant took the deceased along with him on his Hero Honda motorcycle to a sugarcane grove in Shahapur village belonging to complainant Arun Kumar Minache. 
• At approximately 10:00 PM on the same night, the appellant allegedly shot the deceased dead with the gun, committing the offence under Section 302 of the Indian Penal Code (murder). 
• After committing the alleged murder, the appellant took the deceased's Nokia mobile phone and gold chain, thereby committing the offence of misappropriation under Section 404 of the IPC. 
• The appellant was also charged under the Arms Act for carrying and using the gun without a valid license (Sections 3 and 5 punishable under Sections 25 and 27 of the Arms Act). 
• When the deceased did not return home, his father searched for him and filed a missing person report after the appellant gave false information about the deceased's whereabouts. 
• The deceased's decomposed body was discovered in the sugarcane field on 13th July  2006, and was later identified by his father through photographs and personal belongings found with the body. 

What were the Court’s Observations? 

• Standard of Proof in Circumstantial Evidence: The law does not require that a fact be proved on absolute terms bereft of all doubts. What law contemplates is that for a fact to be considered proven, it must eliminate any reasonable doubt. Reasonable doubt does not mean any trivial, fanciful or imaginary doubt, but doubt based on reason and common sense growing out of the evidence in the case. 
• Chain of Circumstances: Each of the circumstances from which certain inferences are sought to be drawn is required to be proved in accordance with law, and there cannot be any element of surmise and conjecture. Each of these circumstances so proved must form a complete chain without any break to clearly point to the guilt of the accused person. 
• Motive in Circumstantial Evidence Cases: While proof of motive certainly strengthens the prosecution case based on circumstantial evidence, failure to prove the same cannot be fatal. The law is well-settled that proving one's motive is a difficult task, as it remains hidden in the deep recess of the mind of the person concerned. 
• Burden of Explanation: When prosecution has been able to prove on the basis of cogent evidence that the weapon of crime was traced to the accused, it becomes incumbent upon the appellant to explain the circumstances of the recovery of the weapon with which a linkage has been established with the injury suffered by the deceased through scientific evidence. 
• Silence of Accused: In cases based on circumstantial evidence, when incriminating circumstances are put to the accused and the accused either offers no explanation or offers an explanation which is found to be untrue, the same becomes an additional link in the chain of circumstances to make it complete. 
• Cumulative Effect of Circumstances: The court has to examine the cumulative effect of the existence of these circumstances, which would point to the guilt of the accused, though any single circumstance may not in itself be sufficient to prove the offence. These circumstances so proved must be consistent only with the hypothesis of the guilt of the accused and should exclude every hypothesis except the one sought to be proved. 
• Complete Chain Without Break: If the combined effect of all these circumstances, each of which has been independently proved, establishes the guilt of the accused, then the conviction based on such circumstances can be sustained. A clear pattern must emerge out of the circumstances so proved with inferential and logical links which unmistakably points to the guilt of the appellant for committing the offence. 

Cases Referred 

Sharad Birdhichand Sarda v. State of Maharashtra (1984)  

• Principle: This case succinctly explains the five golden principles of law governing trials based on circumstantial evidence 
• Significance: Fundamental decision establishing the framework for evaluating circumstantial evidence cases 

Hanumant v. State of Madhya Pradesh (1952)  

• Principle: Most fundamental and basic decision on circumstantial evidence 
• Key Observation: "In cases where the evidence is of a circumstantial nature, the circumstances from which the conclusion of guilt is to be drawn should in the first instance be fully established, and all the facts so established should be consistent only with the hypothesis of the guilt of the accused." 
• Significance: Has been uniformly followed and applied by the Supreme Court in numerous later decisions 

What is Section 6 of Bharatiya Sakshya Adhiniyam, 2023 (BSA) ? 

• Section 6 of the BSA establishes the relevancy of facts showing motive, preparation, and conduct in legal proceedings.  

The provision encompasses two key aspects: 

• Sub-section (1) - Motive and Preparation 
  • Any fact is relevant which shows or constitutes a motive or preparation for any fact in issue or relevant fact. 
• Sub-section (2) - Previous or Subsequent Conduct 
  • The conduct of any party, agent, or person (in criminal proceedings) is relevant if such conduct influences or is influenced by any fact in issue or relevant fact, whether such conduct was previous or subsequent to the fact in issue. 
• Key Principles 
  • Motive Evidence: Facts demonstrating why a person would commit an act are admissible to establish connection between the accused and the offence. 
  • Preparation Evidence: Acts showing systematic planning or readiness to commit the offence are relevant to prove intention and premeditation. 
  • Conduct Relevancy: Both pre-crime and post-crime behaviour is admissible if it has logical connection to the facts in issue, including:  
    • Absconding after commission of crime 
    • Destroying or concealing evidence 
    • Procuring false witnesses 
    • Flight upon discovery 
    • Possession of stolen property 
    • Temporal Scope: The section covers conduct occurring before, during, or after the alleged incident, provided it influences or is influenced by the fact in issue. 
    • Exclusion of Statements: Pure statements are excluded unless they accompany and explain acts, though they may be relevant under other provisions of the Act.